Category Archives: Business

In his recent InformationWeek article entitled “Let The UBS Trial Be A Warning To You” Mitch Wagner covers the trial against a former UBS employee charged with hacking the company’s networks. The article also addresses some of the embarrassing failures in UBS’s security and disaster preparedness.

According to testimony from a UBS IT manager, some 40 systems administrators at the company shared the same ‘root’ password to login. There they had free rein to install software or make any changes they wished. It was not unusual for systems administrators to get up from their desks and wander off while still logged in as ‘root’.

It is a fact that companies often spend millions implementing the latest and greatest security technology. The rationale is that technology will keep us secure.

The reality is that the best security technology is not worth a dime if people find a way around it. People must me trained and reminded of proper security procedure. For example don’t share passwords, it’s like giving your ATM card and PIN to anyone who asks, delete default passwords, remember Oracle’s Scott/Tiger and most everyone else’s Admin/Admin.

But in my experience, Post-it® notes are security’s worst enemy. I cannot tell you how many times I walk up to someone’s desk and stuck to the monitor is a Post-it® notes with a list of system names and their respective passwords.

The path to security begins with people. Let’s not confiscate all Post-it® notes in the company. Instead, let’s train our people on proper security procedures.

SAFE is designed for the purpose of simplifying, securing, and streamlining business-to-business and business-to-regulator information exchange. The SAFE standard consists of policies, procedures, guidelines, technical specifications and a legal and liability risk management framework for ensuring the validity of the electronic signatures used for information exchange and electronic submissions to regulators.

The SAFE standard promotes interoperability and integration among researchers, vendors, regulators, clinicians and other pharmaceutical and healthcare stakeholders. It provides a secure, enforceable, and regulatory compliant way to verify the identities of parties involved in business-to-business and business-to-regulator electronic transactions.

As one of the world’s largest management and technology consulting firms, BearingPoint will add significant momentum to the SAFE initiative. After all, if there is one thing big consulting firms can do it’s to sell technology.

In a long awaited move, the FDA announced on Friday June 9th, that it will fully implement regulations related to the Prescription Drug Marketing Act of 1987, which requires drug distributors to provide documentation of the chain of custody of drug products — “pedigree” — throughout the distribution system.

Consistent with recommendations from the FDA Counterfeit Drug Task Force, the agency also announced that its enforcement of the pedigree regulations will focus on products most susceptible to counterfeiting and diversion.

FDA also announced the availability of a Draft Compliance Policy Guide for public comment describing this enforcement approach. By providing guidance on the types of drugs that are currently of greatest concern to FDA, the agency intends to give wholesale distributors a better idea on where and how to focus their initial energies to come into complete compliance with the regulations (21 CFR Part 203) for all the prescription drugs they distribute.

Additional subjects discussed in the Task Force’s report include the following key issues related to electronic track-and-trace that are in need of resolution:

Technical aspects of the mass serialization of marketed drugs by assigning a unique identifier or serial number to each drug package as the initial step in development of track and trace technology.

Importance of a nationwide universal drug pedigree with uniform information in preference to state laws imposing different pedigree requirements.

Protection of consumer privacy to prevent unauthorized disclosure of information stored in RFID tags when RFID-tagged drug products are dispensed to consumers.

Consumer education about RFID and the labeling of RFID-tagged drug products, to disclose to consumers when they are receiving RFID-tagged products and to inform consumers of the benefits of RFID technology and how consumers’ privacy is being protected.

The FDA has been busy providing guidance and direction on these important topics, now its time for the industry to move implementation into high gear.

The Life-Sciences industry is undergoing a metamorphosis. Historically separate disciplines, like pharmaceuticals, devices, diagnostics, biotech, and even nanotech, are converging.

This trend will accelerate as personalized medicine and genetic therapies evolve. In the not to distant future, your Doctor will be able to target specific medical treatments to address your condition based on your unique DNA.

This shift to convergence medicine is already underway with the combination of traditional pharmaceuticals and medical devices. Products like drug coated stents and antibacterial sutures are breaking down the traditional barriers in healthcare.

Today, pharmaceutical companies are looking to biotech firms for innovation and new ways to treat conditions.

Read more about this trend and my opinion on it in Chemicals to Cell Culture published in this month’s issue of Intech Magazine.

Do you know that tense moment during the wedding ceremony, when the officiant says “speak now or forever hold your peace?” What happens if someone objects? Usually there are two outcomes, either the wedding is off or a brawl breaks out.

This is NOT one of those moments, and in this case, I would encourage you to speak your peace.

This Guidance is part of the U.S. Food and Drug Administration (FDA) Medical Device Innovation Initiative. This initiative is aimed at making new medical devices available more quickly for patients.

“We must keep up with the rapid developments in science and technology to ensure that patients have access to the most advanced treatments available,” said FDA Acting Commissioner Andrew C. von Eschenbach, M.D. “By working with industry early in the evaluation process, we hope to foster development and speed up the approval of safe and effective innovative devices.”

The Medical Device Innovation builds on the successes of MDUFMA and further modernizes the medical device review process in order to improve patient health and safety.

As part of this initiative, the Center for Devices and Radiological Health (CDRH) will expand current efforts to promote scientific innovation in product development, focus device research on cutting edge science, modernize the review of innovative devices, and facilitate a least burdensome approach to clinical trials.In addition, this initiative includes:

Providing Regulatory Clarity Through Guidance Development

Investment in Critical Path

Conducting Stakeholder Outreach and Improve Communications

Laboratory Research to Support Efforts to Improve the Device Development Process

Implementation of a Quality Review Program

Leveraging Information Technology Solutions

Expanding Clinical and Scientific Expertise at FDA

The comments period expires 90 days from publication in the Federal Register announcing the availability of the draft guidance.

You can submit written comments (usually after checking with Legal and/or Compliance) to the Division of Dockets Management (HFA-305), Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You can also submit electronic comments http://www.fda.gov/dockets/ecomments. All comments should be identified with docket number 2006D-0191.

So this is your chance, Speak Now or Forever Hold your Peace.

Well, maybe not forever, but at least until the next guidance document comes along.

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